Obligations of Member Firms

Accountants are key gatekeepers for the financial system, facilitating vital transactions that underpin the economy. As such, they have a significant role to play in ensuring their services are not used to further a criminal purpose.

BICA supervises and regulates all practising member firms for compliance purposes with the Financial Intelligence Act and Regulations 2019 (‘FI Act’). The FI Act aims to ensure that member firms have the most appropriate and proportionate measures to deter, detect and disrupt money laundering and the financing of terrorism and proliferation.

Member firms are therefore encouraged to perform their obligations under the FI Act, review their entity’s risks and vulnerabilities and put in place an AML/CFTP programme to protect their business and clients. These obligations include but are not limited to the following;

  • Appointment of a fit and proper Compliance Officer
  • Carry out a firm-wide risk assessment to understand the money laundering and terrorist financing risks the firm faces;
  • Establish, maintain and regularly review policies, controls and procedures to mitigate and manage effectively the risks identified through a firm-wide risk assessment. e.g. keeping of records, monitoring unusual business;
  • Carry out proper customer due diligence on clients, which includes a risk assessment of the money laundering risks of the client and verify the client’s identity and source of funds (where appropriate);and
  • Train all staff so that they can properly identify AML/CFTP risks, red flag indicators and suspicious activities.
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